Italy’s updated e-invoicing archiving requirements

Italy introduced mandatory B2B e-invoicing via its Sistema di Interscambio (SDI) platform from 1 January 2019. There has however, always been strict legislation in Italy governing e-invoicing data archiving. Not only must taxpayers keep e-invoice data archived for at least 10 years from the date of the last record, but they must also appoint a Conservation Manager (the “Responsabile della Conservazione”) and produce a Conservation Manual (the “Manuale della Conservazione”). Throughout the 10 year retention period mandated under the Italian Civil Code, the archived e-invoices cannot be altered and are required to be grouped into archived packets (“Pacchetti di Archiviazione”) and have a digital signature and a time stamp applied. This archiving process must be completed no later than three months after the submission deadline for the Annual Income Tax Return.

Conservation Manager (“Responsabile della Conservazione”)

The Conservation Manger is responsible for defining and implementing the company’s policies relating to the conservation system used for archiving and document management.

Conservation Manual (“Manuale della Conservazione”)

The Conservation Manual sets out the processes and controls relating to the archiving of e-invoices. The manual must set out how the business meets the technical and tax requirements defined in the “Guidelines on the formation, management and archiving of electronic documents” issued by the Agency for Digital Italy (Agid) which was updated with effect January 1, 2022. This includes:

• The details of the persons who have assumed responsibility for the archiving system
• The corporate structure and obligations of the various parties involved in the e-archiving process
• The description of the types of electronically archived documents and related metadata
• Description of the preservation process
• Reference to the relevant legislation
• Relevant security protocols to protect the archive. 

Historically, the Conservation Manual was often drafted or provided by third parties, usually the e-invoicing solution provider or implementer. However, with effect January 1, 2022, the drafting of the Manual can no longer be delegated to third parties and instead it must be drafted internally by the Conservation Manager, responsible for archiving e-invoices within the company.

Complaint archiving is just one of the many key issues and main business requirements when implementing e-invoicing. The direction of travel for Governments and tax authorities is clear, and more countries are announcing new e-invoicing mandates. As a result, businesses are starting to think strategically rather than tactically and seeking to implement an e-invoicing solution that is scalable across countries and regions rather than purchase multiple individual local solutions as and when new mandates appear.

Find out more about Avalara’s e-invoicing solution.